Courts cannot interfere with the investigating agency’s domain or supervision reports absent perversity or patent mala fides.

The petitioner, Basudeo Rai, filed a writ petition seeking a mandamus for an impartial investigation into Mohanpur P.S. Case No. 114 of 2025.

The case arose from a domestic dispute where the petitioner's daughter-in-law (Respondent No. 7) allegedly assaulted him with an iron rod and brick.

Initially, a Sub-Divisional Police Officer's supervision report included Section 109 of the B.N.S., 2023.

However, a subsequent second supervision report by the Deputy Superintendent of Police (HQ) omitted Section 109, rendering the case bailable.

The petitioner sought the quashing of this second report, alleging it was improper and favored the accused.

1. Whether the High Court should exercise its writ jurisdiction to interfere with an ongoing police investigation and quash a specific supervision report.

2. Whether the omission of a specific section (Section 109 B.N.S.) in a supervision report during investigation constitutes a miscarriage of justice requiring judicial intervention.

The court emphasized the principle of judicial non-interference in the domain of the investigating agency.

Courts should not interfere with investigation proceedings unless there is perversity or "complete malafide writ large on the face of record".

A complainant has an alternative remedy to raise concerns regarding the inclusion or exclusion of specific charges at the stage of taking cognizance or framing of charges under the Bharatiya Nagarik Suraksha Sanhita (B.N.S.S.)/Cr.P.C.

The Court observed that the dispute was a domestic matter where the injuries sustained by the petitioner were found to be "simple" and caused by blunt objects.

The Court reasoned that the Deputy Superintendent of Police (HQ) acted impartially, as he had also categorized a counter-case filed by the daughter-in-law as "non-cognizable".

The Court found no evidence of bias or malafide in the removal of Section 109 B.N.S.

It further held that it cannot substitute its own views for those of the investigating officer, nor can it allow a petitioner to insist that only their version of events be recorded.

The court noted that since the chargesheet was not yet filed, the petition was premature.

The Court ruled that judicial intervention in the investigation is unwarranted absent manifest perversity.

Regarding the petitioner's grievance over the omission of Section 109 B.N.S., the Court held that the petitioner is at liberty to raise this issue before the trial court at the stage of cognizance or framing of charges.